Tax Law Specialist 12 Month Roster
Company: Contra Costa County Bar Association
Location: San Rafael
Posted on: January 27, 2023
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Job Description:
DutiesWHAT IS THE LARGE BUSINESS/INTERNATIONAL-LBI DIVISION?A
description of the business units can be found at: position is
located in the Large Business and International (LB&I) Division
of the Internal Revenue Service (IRS).* The International Transfer
Pricing Specialist is an expert in the analysis and application of
relevant law to significant international tax compliance issues
relating to Internal Revenue Code (IRC) 482 and corresponding
Treasury Regulations. The incumbent collaborates directly with IRS
Examination Teams relating to the development of audit plans, fact
gathering, and the preparation of position papers, including Forms
5701 (Notice of Proposed Adjustment). The incumbent participates as
a technical expert in tax compliance examinations and provides
expert advice that may impact tax policy and the International
Examination Program as a whole. The incumbent may participate as a
member of IRS teams, including but not limited to Practice Networks
(PNs), and on other projects or assignments focused on specific
international tax issues. The incumbent may coordinate or
participate in a national tax compliance task force.* Assists
Examination Teams in planning, directing, and coordinating the
examination of international transfer-pricing issues. The incumbent
serves on a consulting basis for other Examination and
International Specialists, Counsel Attorneys, Appeals Officers, and
Revenue Agents regarding the examination of transfer-pricing issues
and transactions. The incumbent may also be assigned to work
closely with IRS Examination Teams on multiple examinations
simultaneously.* Collaborates and coordinates with Examination and
International Specialists, Counsel Attorneys, Appeals Officers, and
Revenue Agents to leverage and expand international issue expertise
throughout the IRS, and to ensure consistent application and
interpretation of international tax law. The incumbent regularly
participates in groups focused on international issues including,
but not limited to, PNs; and interacts regularly with personnel in
the Advance Pricing and Competent Authority programs (APMA).*
Participates in long-term projects involving the development of new
auditing techniques, work practices, and training programs for
Examination Specialists, Counsel Attorneys, Appeals Officers, and
Revenue Agents. The incumbent may be assigned to develop and
conduct training sessions and hold periodic meetings with IRS
personnel at national and local office levels to review all matters
relating to international transfer-pricing.* Performs research and
analysis of tax issues involving economics, transfer pricing, and
valuation related to specific taxpayers or across taxpayers and
industries.* Provides feedback, technical expertise, and
recommendations to IRS management and IRS Counsel on
transfer-pricing issues. The International Transfer Pricing
Specialist identifies and discusses any issues that require
technical advice, field service advice, or industry-wide
coordination procedures to be followed.* Meets with taxpayers,
industry representatives, members of professional associations, and
national tax administrators to explain IRC 482 transfer-pricing
issues, and to seek alternate resolution opportunities. Also
provides specialized assistance to other governmental agencies and
national tax administrations regarding tax matters relating to
transfer-pricing issues.* Coordinates, leads, or collaborates with
the national analyses of tax issues involving significant
international transfer-pricing transactions related to specific
taxpayers or across taxpayer, industry, and international
boundaries.HelpQualifications:Federal experience is not required.
The experience may have been gained in the public sector, private
sector or Volunteer Service. One year of experience refers to
full-time work; part-time work is considered on a prorated basis.
To ensure full credit for your work experience, please indicate
dates of employment by month/year, and indicate number of hours
worked per week, on your resume.You must meet the following
requirements by the closing date of this announcement:SPECIALIZED
EXPERIENCE: GS-14 LEVEL: You must have 1 year of specialized
experience at a level of difficulty and responsibility equivalent
to the GS-13 grade level in the Federal service. Specialized
experience for this position includes:Experience with application
of tax law to transfer pricing projects, transactions, and
controversies, including application of the Internal Revenue Code,
corresponding Treasury Regulations, tax treaties, Court decisions
and the Organization for Economic Cooperation and Development
(OECD) Guidelines related to transfer pricing between US and
foreign related parties including transfers of tangible and
intangible property, high value services, asset valuations, and
risk allocation; Applying auditing techniques to multiple,
interrelated transfer pricing issues as listed above on large
corporate returns. Performing research and analysis of transfer
pricing issues; conducting various kinds of audit steps verifying
taxpayers' economic structure, business practices and functions;
reviewing and analyzing economic, financial, operational and tax
data to determine the existence of a potential transfer pricing
issue; performing analyses to determine and/or evaluate tax
reporting of intercompany transactions; providing technical advice
concerning transfer pricing issues on cases; providing advice and
recommendations to other examiners within issue networks during
workshops and other knowledge sharing forums. Experience preparing
and delivering written and oral communications to explain and
defend the Government's position related to transfer pricing;
holding conferences with taxpayers, their representatives and
others to present and discuss transfer pricing positions and
analysis; Experience serving, where necessary, as a qualified
witness for the government in litigation cases. Experience
assisting on competent authority cases or advance pricing
agreements; correlative adjustments, set offs, or commensurate with
income; and experience with treaty partners such an exchange of
Information (EOI), Joint Audit, or International Compliance
Assurance Program (ICAP). ANDMEET TIME IN GRADE (TIG) REQUIREMENT:
For positions above the GS-05, applicants must meet applicable
time-in-grade requirements to be considered eligible. One year (52
weeks) at the next lower grade level is required to meet the
time-in-grade requirements for the grade you are applying
for.ANDTIME AFTER COMPETITIVE APPOINTMENT: By the closing date (or
if this is an open continuous announcement, by the cut-off date)
specified in this job announcement, current civilian employees must
have completed at least 90 days of federal civilian service since
their latest non-temporary appointment from a competitive referral
certificate, known as time after competitive appointment. For this
requirement, a competitive appointment is one where you applied to
and were appointed from an announcement open to "All US
Citizens".For more information on qualifications please refer to
OPM's Qualifications Standards.
Keywords: Contra Costa County Bar Association, San Rafael , Tax Law Specialist 12 Month Roster, Accounting, Auditing , San Rafael, California
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